Tax Attorney in Los Angeles, California

The U.S. Tax Court holds Los Angeles trial sessions at the Edward R. Roybal Federal Building, 255 E. Temple Street, Room 1174, Los Angeles 90012. Multiple sessions are scheduled each year. A petitioner designates the preferred place of trial in the petition under Tax Court Rule 140. Los Angeles is one of five Tax Court trial cities in California, alongside San Diego, San Francisco, Sacramento, and Fresno. The Roybal Federal Building also houses the U.S. District Court for the Central District of California, the U.S. Bankruptcy Court, and federal prosecutor offices, putting most federal tax venues a short elevator ride apart.

The IRS operates several Taxpayer Assistance Centers in and around the City of Los Angeles: Westwood (11000 Wilshire Blvd, LA 90024), Downtown LA (300 N. Los Angeles Street, LA 90012), El Monte (9350 Flair Drive), and outside the city proper, Long Beach (501 W. Ocean Blvd) and Glendale (225 W. Broadway). Appointments are required at apps.irs.gov/app/office-locator or by calling 844-545-5640. IRS Examination and Collection field offices for Los Angeles are separate from the TACs — representatives generally interact with field offices by phone or by appointment after Form 2848 is filed.

The two are different jurisdictions and the distinction drives real money. Los Angeles County is the most populous county in the United States, covering 4,083 square miles and 88 incorporated cities including LA, Beverly Hills, Santa Monica, Burbank, Glendale, Long Beach, Pasadena, Culver City, and West Hollywood, plus large unincorporated areas. The City of Los Angeles itself covers 472 square miles inside LA County, with about 3.9 million residents. LA County levies property tax through the LA County Assessor and Treasurer-Tax Collector; the City of LA layers its own LA Business Tax under LAMC §21.00, Transient Occupancy Tax, Utility Users' Tax, Parking Occupancy Tax, and Communications Users' Tax on top. A business in Beverly Hills, Santa Monica, Culver City, Glendale, Burbank, or West Hollywood owes the local municipal tax of that city rather than LA Business Tax. Getting the boundary right is the first practical question on every LA-area business-tax matter.

An LT11 or CP90 Final Notice of Intent to Levy starts a 30-day clock under IRC §6330. During that window you can file Form 12153 to request a Collection Due Process hearing, which pauses federal levy enforcement and preserves U.S. Tax Court review out of the LA trial session at the Roybal Federal Building. If the 30 days lapse without a CDP filing, you can still pursue an Equivalent Hearing on the same form, but you lose Tax Court rights. Either way, do not ignore the notice — the IRS can issue wage and bank levies after day 30 without further notice. Call us; we can file the CDP request and a parallel collection alternative the same day.

Often yes, and Los Angeles is the single biggest source of California-departing-resident audits. California uses the domicile test at Cal. R&TC §17014, fleshed out in FTB Publication 1031, which weighs nine factors: time in state, location of family, location of primary residence, where you hold a driver's license, where you register vehicles, where you vote, where you bank, where you maintain professional licenses, and where you have business or social ties. The FTB pursues departing Los Angeles residents — especially those moving to Austin, Houston, Dallas, Las Vegas, Reno, Miami, Tampa, Nashville, or Seattle — on a theory that the move was incomplete or pretextual under the closer-connection analysis. Appeal of Stephen Bragg (2003-SBE-002), Appeal of Bindley (2018), and Corbett v. FTB are the cornerstone cases. We typically see FTB residency audits run one to three years after the move out of LA. A clean break documented at the time of the move — deed transfers, voter registration, driver's license, professional licensing, primary-care physician, bank relocation, and the family-presence factor — is the strongest defense.

A loan-out S-corp is a common entertainment-industry structure that converts 1099 self-employment income into S-corp W-2 wages plus distributions. The federal issues: reasonable-compensation analysis to support the W-2/distribution split, IRC §199A Qualified Business Income deduction (the SSTB carve-out for performing-arts professionals above income thresholds), SEP-IRA or solo 401(k) funding limits, federal payroll-tax compliance on the W-2 leg, and self-employment health-insurance deduction interplay. The California issues: the $800 annual minimum franchise tax under Cal. R&TC §23153, FTB residency analysis when work happens out of state, EDD payroll-tax compliance on the W-2 portion, and the 1.5% S-corp tax on top of the C-corp franchise tax under Cal. R&TC §23802. SAG-AFTRA pension-and-health contributions on residuals and royalties are separately handled under §401(a). Loan-outs routinely fall behind on quarterly estimates after a single down year — the seasonality of entertainment income is the structural risk that drives most of the federal IA work we do on this category.

Most LA tech and streaming employers withhold federal tax on RSU vests at the supplemental rate of 22 percent, which is often well below the marginal rate of a high earner. The shortfall lands on the April Form 1040 as a balance due. For employees with $250,000-plus in annual ordinary income, the supplemental withholding gap can be $30,000 to $90,000. The fix on a forward-looking basis: increase Form W-4 step 4(c) additional withholding, make quarterly estimated payments under IRC §6654, or sell-to-cover at vest rather than net-share-settling. On a back-looking basis: a streamlined IRS Installment Agreement under IRC §6159 handles balances up to $50,000 with no Form 433 financial disclosure; larger balances move to non-streamlined IA, Partial Pay IA, or OIC depending on the financial picture. The California parallel runs through FTB Form 3567. ISO exercises during a strong year add AMT preference items under IRC §55 even without a sale.

A Notice of Federal Tax Lien under IRC §6321 is filed with the LA County Registrar-Recorder/County Clerk in Norwalk. It clouds title on every parcel you own anywhere in LA County and shows in every credit and title check. Four release paths: full payment (lien releases within 30 days under IRC §6325(a)), accepted Offer in Compromise (release follows acceptance and payment), withdrawal under Fresh Start (available for streamlined IAs under $25,000 paid by direct debit), and certificate of discharge for a specific property (allows you to sell or refinance one parcel while the lien remains on the rest). FTB State Tax Liens release or withdraw separately under Cal. Gov. Code §7174. Both releases need to be recorded with the LA Recorder to clear title.

CDTFA audits cash-intensive restaurants out of its Culver City field office using mark-up methodology, observation tests, and POS-to-deposit reconciliation. The auditor takes a small test sample, calculates a presumed mark-up, and projects it across the entire audit period — often three years. The defense is challenging the test-period sample early: documenting comps and waste, separating tax-exempt to-go beverage sales, identifying delivery-platform commissions that did not pass through to revenue, and demonstrating mark-up variance by menu segment. If the test period is sound, the projection sticks; if not, the entire assessment unravels. Common LA targets: Koreatown KBBQ, Westside delis, Highland Park nightlife, DTLA hospitality, and Fairfax breakfast spots. We respond to CDTFA observation reports, prepare records for the auditor visit, and pursue redeterminations and OTA appeals where the assessment is wrong.

FinCEN Form 114 (the FBAR) is required of any U.S. person with signature authority or financial interest in foreign accounts whose aggregate value exceeds $10,000 at any point during the year. Form 8938 under FATCA layers additional reporting at higher thresholds. Penalties under 31 USC §5321 reach $10,000 per non-willful violation per year and the greater of $100,000 or 50 percent of the account balance per willful violation. Three remediation paths exist: Streamlined Filing Compliance Procedures (non-willful, abbreviated penalty), Delinquent FBAR Submission Procedures (no unreported income), and IRS Voluntary Disclosure Practice (potential criminal exposure). Each path has narrow eligibility criteria; submitting under the wrong one creates new problems. LA carries the largest Persian diaspora in the United States, one of the largest Korean populations outside Korea, and substantial Armenian, Chinese, Filipino, and Israeli communities — FBAR work is a core area of our practice. Always reach out before the IRS contacts you; eligibility narrows materially once a letter arrives.

Prop 19 (effective February 16, 2021) replaced the broader Prop 58 parent-to-child base-year-value transfer rule. Under the current Cal. Const. Art. XIII A, a parent-to-child transfer of a primary residence keeps the parent's base-year value only if the child makes the property the child's own principal residence within one year. If the child rents it out, the property reassesses to current fair market value. There is also a $1 million increment above the parent's base value that resets — significant for high-value LA properties in Bel Air, Hancock Park, Brentwood, Beverly Glen, the Hollywood Hills, Cheviot Hills, Beverlywood, Sherman Oaks, and Studio City. Investment-property transfers no longer benefit at all. The LA County Assessor at 500 W. Temple Street administers the reassessment; the LA County Assessment Appeals Board hears valuation disputes. Estate planning around Prop 19 is now a different exercise than it was pre-2021.

Yes. IRC §7345 authorizes the IRS to certify seriously delinquent federal tax debt — $62,000 for 2026, indexed for inflation — to the State Department, which may then deny passport renewal or revoke an active passport. Certification reverses when the debt is paid, an IA is in place, an OIC is accepted, an active CDP hearing is pending, or Innocent Spouse Relief is in process. We handle decertification routinely for LA-based entertainment talent traveling to international festivals (Cannes, Berlin, Venice, Toronto, Sundance), aerospace executives on overseas contracts, and Persian, Korean, Armenian, and Chinese diaspora clients with family abroad and travel plans.

Probably, if your business is located within the City of Los Angeles boundaries or you do business inside the city. The LA Business Tax under LAMC §21.00 et seq. is a gross-receipts tax administered by the LA City Office of Finance at 200 N. Spring Street. Rates vary by business classification — the rate per $1,000 of gross receipts is different for retail, services, professional services, entertainment, construction, and a long list of specific categories. Important nuances include the Creative Artist Exemption that excludes certain entertainment-industry creative work, the apportionment rules for multi-jurisdictional gross receipts, the small-business exemption thresholds, and the new-business exemption for the first two years. Office of Finance audits target classification disputes, apportionment, and the Creative Artist Exemption. We represent LA businesses through administrative appeals and into LA County Superior Court refund actions under R&TC §5140 where the assessment is wrong.

Mello-Roos Community Facilities District taxes are authorized under the Mello-Roos Community Facilities Act of 1982, Cal. Gov. Code §53311 et seq. They fund infrastructure — schools, parks, streets, fire stations — in specific districts, and they show up on the LA County property-tax bill as a separate line item. CFD taxes were approved by two-thirds voter (or landowner) consent at formation, so a head-on legal challenge is narrow. The realistic claims: (1) the CFD tax is incorrectly calculated for your parcel under the rate-and-method document, (2) the CFD has expired or has been retired, or (3) the property classification changed and the tax should be reduced. These run through the LA County Assessor or the relevant district administrator rather than the AAB. We map the CFD obligations against the title and the rate-and-method, identify miscalculations, and pursue refund where appropriate. Newer LA developments in Playa Vista and parts of the San Fernando Valley carry CFD overlays; many older LA neighborhoods do not.

The IRC §6213(a) 90-day window to petition U.S. Tax Court is normally jurisdictional. However, IRC §7508A authorizes the IRS to postpone deadlines for taxpayers in a federally-declared disaster area, and the IRS issues notices listing the affected ZIP codes and the postponement period for each LA disaster (Palisades January 2025, Eaton January 2025, Woolsey 2018, Skirball 2017). The postponed window applies if your home or business address is inside a covered ZIP code. Tax Court itself also extended deadlines after the January 2025 fires for petitioners affected by the disaster. The mechanical answer: pull the IRS disaster notice for your fire, confirm the address is covered, and file the petition with proof of disaster-zone residence attached. If the postponement does not cover you, the deadline is gone — but you can still pursue audit reconsideration, an Offer in Compromise on doubt-as-to-liability grounds, or a refund suit after paying.

Yes. EDD audits of LA production companies, post-production houses, talent agencies, and gig-platform operators apply the ABC test codified at Cal. Lab. Code §2775. Production assistants, gaffers, makeup artists, drivers, security, and crew classified as 1099 contractors get reclassified as W-2 employees absent a qualifying exemption. Defense relies on the AB 5 carve-outs at §2783 (covering specific entertainment-industry categories including some still-photographers, freelance writers, and others), the business-to-business exception at §2776 for bona-fide business-to-business contracting, and the referral-agency exception at §2777. EDD assessments hit the entity for back contributions and hit responsible individuals personally under Cal. Unemp. Ins. Code §1735. EDD field auditors out of the LA-area offices handle most LA-production audits. We respond to the initial questionnaire, prepare the worker-classification analysis, and appear at the EDD hearing or OTA appeal.

No. Most LA engagements run by phone, secure portal, and email. The 1100 S. Robertson Boulevard office is available by appointment for clients who prefer face-to-face meetings — particularly for sensitive matters, criminal-adjacent investigations, or for clients in the Westside, Beverly Hills, Hancock Park, Mid-City, Culver City, Pico-Robertson, Beverly Grove, and West LA who find it convenient. Clients in Hollywood, the San Fernando Valley, the Eastside (Echo Park, Silver Lake, Boyle Heights, El Sereno), South LA, the Harbor area (San Pedro, Wilmington), and the South Bay generally engage remotely. The level of in-person work depends on the case — an OIC rarely needs an in-person meeting; a complex audit, a criminal-adjacent investigation, or a Tax Court trial preparation often does.

Yes. Communications between you and a California-licensed attorney for the purpose of seeking legal advice are protected by California Evidence Code §954 attorney-client privilege and the parallel federal common-law attorney-client privilege, subject to the usual exceptions (crime-fraud, waiver). The narrower federally-authorized tax practitioner privilege under IRC §7525 applies to CPAs and EAs but does not extend to criminal-tax matters. A California-bar attorney handling your tax case retains the broader privilege that survives criminal investigation — relevant for FBAR willfulness analysis, cannabis-industry §280E exposure, and ERC promoter-mill clawback cases where criminal referral is on the table.

Federal tax-resolution fees vary by matter complexity. A straightforward Installment Agreement typically falls between $1,500 and $3,500. A full Offer in Compromise with Form 433 financial analysis runs $4,000 to $7,500. Audit defense depends on the audit type and the number of issues. A U.S. Tax Court petition with case workup and trial preparation generally starts at $6,000 and rises with complexity. California-state matters (FTB, CDTFA, EDD, OTA) and LA City Office of Finance matters are priced separately. VTL provides a written fee quote after the free consultation. Cal Bar Rule 7.1 prohibits comparative price claims without verifiable substantiation, so we do not market on price.

Property tax in LA County is administered by two separate offices. The LA County Assessor at 500 W. Temple Street sets the assessed value under Prop 13, Prop 19, supplemental-assessment rules, and the Mello-Roos CFD overlay where applicable. The LA County Treasurer-Tax Collector at 225 N. Hill Street handles billing, collection, and tax-defaulted property sales. Disputes over assessed value go to the LA County Assessment Appeals Board through an application filed July through November 30 each year (with a separate 60-day window on supplemental notices). Our practice focuses on income tax, employment tax, sales-and-use tax, and city business tax (IRS, FTB, CDTFA, EDD, LA City Office of Finance). For pure property-tax assessment appeals before the AAB, the procedure is its own filing process and we will refer to property-tax specialty counsel where that is the entire matter. When the property issue overlaps with a federal lien, FTB lien, Prop 19 transfer analysis, transferee liability, or trust funding, we handle the full picture.

IRC §181 allows an immediate election to expense qualified film and television production costs (up to $15M, or $20M for productions in low-income or distressed areas) in the year of expenditure rather than capitalizing under IRC §168 or §167. The election was extended through 2025 by the SECURE 2.0 era legislation; current-year availability depends on the production's first day of principal photography and the most recent congressional extension. IRS audit issues center on: (1) was 75% of total compensation paid to U.S. labor as required, (2) is the election timely filed with the original return, (3) is the qualified production designation supported, (4) was the at-risk basis properly tracked under IRC §465, and (5) for partnerships, did the K-1s flow through correctly. We defend the election with the production accountant's underlying records, cap-sheet schedules, and SAG-AFTRA contribution backup. Where the election is partially disallowed, we negotiate the capitalization fallback to limit immediate exposure.

Customs and federal income tax intersect for LA-area importers in several patterns: transfer pricing on related-party imports under IRC §482, the IRC §7202 willful-failure-to-pay-tax exposure for customs-duty trust funds, foreign-trade-zone benefits under 19 USC §81a, and FBAR / Form 8938 reporting on the foreign-supplier accounts of an LA importer. We handle the federal tax side of these matters — income tax, transfer pricing, and FBAR / Form 8938 — and partner with customs counsel on the U.S. Customs and Border Protection portion. The Port of LA and the Port of Long Beach together move roughly 40 percent of U.S. containerized imports; the LA importer community is dense, particularly in the apparel and toy districts downtown, and the cross-border tax overlap is constant.